A2 and Bilona Ghee: What the Claims Mean and How to Prove Them

Short answer: "A2" and "bilona" are marketing terms. Neither is defined in FSSAI's standard for ghee. FSSAI told sellers in August 2024 to remove A1/A2 claims from milk and milk products, including ghee. It withdrew that advisory five days later "for further consultation", so the question is still open (FSSAI, 21 Aug 2024; FSSAI, 26 Aug 2024). Every pack of ghee must meet the legal ghee standard, and a lab can test that. An honest A2 or bilona brand shows three more things for each batch: the herd's breed and beta-casein genotype results, a record of how the batch was made, and a lab report that names the batch number. It makes no health promises it can't back up.

This guide covers what each claim officially means, what buyers ask to see, what to record for each batch, and what a shopper can check.

What do "A2" and "bilona" mean, officially?

A2: a protein claim on a fat product

Cow's milk contains a protein called beta-casein. The A1 and A2 forms differ by a single amino acid, at position 67 of the protein chain (Frontiers in Nutrition, 2022). Which form a cow produces depends on her genes.

FSSAI's position so far, from the primary documents:

• 21 August 2024. In an advisory to e-commerce food businesses, FSSAI said that the A1/A2 difference "is essentially linked to difference in structure of protein (beta casein)". It said that "use of any A2 claims on milk fat products is misleading" and does not conform to the FSS Act, 2006. It also said that the milk standards in the Food Products Standards and Food Additives Regulations, 2011 "do not mention/ recognize any differentiation of milk on the basis of A1 and A2 types". Businesses were told to remove the claims, and e-commerce sites were told to take them down immediately (FSSAI advisory, 21 Aug 2024).
• 26 August 2024. FSSAI issued an order saying that the 21 August advisory "stands withdrawn for further consultation and engagement with the stakeholders" (FSSAI order, 26 Aug 2024).
• Since then. We checked FSSAI's published advisories and notifications on 14 October 2026 and found no later notice on A1/A2 claims. So there is no specific rule for or against the term. The general claims rules still apply (see below).

Ghee is at least 99.5% milk fat by law (FSSAI Sixth Amendment, 2021). Beta-casein is a protein, so "A2" on ghee describes the milk the ghee was made from, not something you can easily measure in the jar. That is the point FSSAI made in 2024, and it is why the evidence for an A2 ghee claim has to come from the herd and the milk rather than from the finished ghee.

Desi cow does not automatically mean A2

Indian zebu breeds carry the A2 form at high frequency, but not always at 100%:

• A study published in 2023 genotyped 48 Bargur and 42 Umblachery cattle in Tamil Nadu. It found A1A2 animals in both breeds (6 of 48 and 2 of 42, about 12.5% and 5%), and no A1A1 animals (Raja et al., Indian Journal of Animal Research, 2023).
• The authors call the idea that all zebu cattle carry only A2 "a myth". They write that genotyping of Indian zebu cows "should be obligatory when the milk is sold as A2 milk" (same study).

Breed is a reasonable first claim. If you say "A2", you need genotype results for the animals.

Health claims about A2

The science on A2 and health is narrower than most ghee labels suggest:

• EFSA, 2009. EFSA, the EU food safety authority, reviewed the evidence on beta-casomorphins, the peptides released when A1 beta-casein is digested. It concluded that a cause-and-effect relationship with non-communicable diseases could not be established (EFSA Journal, 2009).
• Later reviews. A 2022 mini-review of earlier reviews, including four systematic reviews, concluded that A2 beta-casein milk was associated with better gastrointestinal outcomes than A1 milk. It also found no evidence that A1 beta-casein has negative effects on human health (Frontiers in Nutrition, 2022).

Both are about milk protein, not ghee. Ghee is at least 99.5% fat, and none of these reviews studied A2 ghee. Nothing here shows that A2 ghee is healthier than other ghee. Under India's Advertising and Claims Regulations, 2018:

• claims must be "truthful, unambiguous, meaningful, not misleading" (regulation 4(1));
• nutrition or health attributes must be "scientifically substantiated by validated methods" (regulation 4(6));
• claims about preventing or treating a disease are prohibited unless another regulation permits them (regulation 10(1)).

A ghee label that promises better immunity, heart health or digestion because it is "A2" is taking on a burden of proof the evidence does not meet.

Bilona: a method, not a defined grade

Bilona usually means setting milk into curd, churning the curd with a wooden churner to get butter, then heating the butter into ghee. The FSSAI standard for milk fat products describes ghee as fat "derived exclusively from milk or products obtained from milk". It notes that ghee "has especially developed flavour and physical structure as a result of its method of manufacturing", but it does not name or define the bilona method (FSSAI compendium, sub-regulation 2.1.8). We found no FSSAI definition of "bilona".

Two parts of the 2018 claims rules matter for bilona sellers:

• "Traditional" may only describe a recipe or processing method that has existed for at least a generation (thirty years) and has stayed substantially unchanged for that period (Schedule V).
• Words like "home-made" or "home cooked", "which may give an erroneous impression to the consumer", shall not be used (regulation 9(2)) (Advertising and Claims Regulations, 2018).

The one ghee with a GI

One ghee does have an official origin definition. Uttarakhand Badri Cow Ghee is the only ghee in IP India's register list published on 2 May 2026 (register list). It is GI application No. 1390. Its registered proprietor is the Uttarakhand Cooperative Dairy Federation Limited, and it was filed on 12 December 2024 in Class 29. The GI Registry record shows its status as registered and lists a "Certificate of Registration" document dated 5 November 2025, although the certificate-number field was blank when we checked. On 14 October 2026 the record listed two authorised users.

The specification published in GI Journal No. 203 (4 July 2025) covers:

• Source: milk from Badri cows, from 11 named districts of Uttarakhand.
• Method: a bilona process. Milk is boiled, cooled and set into curd for about 16 hours in earthen pots. The curd is hand-churned with a wooden churner, and the butter is heated into ghee.
• Inspection: an inspection body that includes representatives of the dairy federation, the state dairy development department, the district administration and producers.

So for this one product, "bilona" has a written, published meaning. For every other ghee, it does not.

What evidence do buyers accept?

Most questions from retailers, distributors and export customers come down to four kinds of evidence. Marketplaces are a focus for regulators: FSSAI's August 2024 A1/A2 advisory, later withdrawn, was addressed to e-commerce food businesses (FSSAI, 21 Aug 2024). In January 2023 FSSAI also asked food safety commissioners to act against plant-based products sold as "ghee", including on e-commerce sites (FSSAI, 23 Jan 2023).

1. It is ghee: a lab report against the FSSAI standard

Since the Sixth Amendment of 2021, ghee has to meet these limits:

The β-sitosterol test looks for plant sterols, which point to vegetable oil mixed into the ghee. The amendment refers to an RP-HPLC method that FSSAI notified in March 2019. Businesses had to comply by 1 July 2022, except for the fatty acid composition, which became mandatory two years after the amendment was published in December 2021. A corrigendum of January 2022 clarified that wording.

A useful report:

• names the test method for each parameter;
• shows the limit next to each result;
• names the batch or lot number printed on the pack;
• comes from a lab whose accreditation covers these tests.

For an example of what a report looks like, the Badri Cow Ghee GI application includes one. It gives a result, limit and method for most of the parameters above (IS 3508:1966 for most constants, AOAC 996.06 for the fatty acids), though it does not show milk fat or β-sitosterol (GI Journal No. 203, via the GI Registry record).

2. It comes from the cows you name: breed and genotype records

• Breed. Records of the herd or the supplying farmers, by animal.
• A2 genotype. For an A2 claim, beta-casein genotype results for the animals whose milk goes into the batch. Genotyping is a DNA test; the Tamil Nadu study above used allele-specific PCR on blood samples (Raja et al., 2023). The result is A1A1, A1A2 or A2A2 for each animal. Only milk from A2A2 animals is A2 milk.
• Changes over time. If the herd changes, through new animals or new suppliers, the genotype record has to keep up.

3. It was made the way you say: process records

For a bilona claim, keep:

• dates of setting the curd and churning;
• a description of the churning equipment (wooden churner, by hand or by motor);
• butter yield;
• heating temperatures and times;
• photos or short videos of the batch being made.

A motorised churn can still make curd-churned ghee, but say so if you use one. "Hand-churned" is a separate, checkable claim.

4. The seller is legal: licence and marks

• FSSAI licence or registration. The number on the label should match the seller. Buyers check it on FSSAI's FoSCoS portal.
• Agmark. If the ghee carries the Agmark grade mark, keep the certificate of authorisation. Ghee grading is now under the Ghee Grading and Marking Rules, 2024, which replaced the 1938 rules (TeamLease RegTech summary; we have not yet read the gazette text).
• GI authorised user. Only for Badri Cow Ghee: the GI authorised-user number.

What should a ghee brand record per batch?

Two points carry most of the weight:

1. Keep A2A2 milk separate. If milk from untested or A1-carrying animals goes into the same churn, the batch is no longer A2 milk ghee. The milk collection record has to show which animals supplied each batch.
2. Test the batch you sell. A lab report from last season, or one with no batch number, does not describe what is in this jar.

How can a shopper check A2 or bilona ghee?

1. Find the FSSAI licence number on the label and look it up on FoSCoS. The business name should match the brand or its manufacturer.
2. Ask for the lab report for the batch number on your jar. Check that it covers the parameters in the table above, including β-sitosterol and the Baudouin test, and that each result is within the limit.
3. For an A2 claim, ask how the herd was genotyped: which lab, when, and how many animals. "Our cows are desi, so the milk is A2" is a claim about a breed, not a test result.
4. For a bilona claim, ask what the process is. Is the milk set into curd? Is the churning done by hand or motor? Are there photos or video of the batch?
5. Be careful with health promises. Claims that A2 ghee prevents or treats a disease are prohibited under regulation 10(1) of the 2018 claims rules unless another regulation specifically permits them.
6. For Badri Cow Ghee, search application No. 1390 on the GI Registry and check that the seller is a listed authorised user.

What a trace page can and can't prove

A trace page is what opens when a shopper scans the QR code on a pack. In IndiTrace, it shows the batch record the brand entered: which farmers supplied the milk (with herd or genotype details as attached documents), the curd and churning dates, the process photos, and the lab report and genotype reports the brand attached for that batch. Each confirmed record is fingerprinted on the Polygon blockchain, which shows it was not edited after it was confirmed.

It can show:

• what the brand recorded about this batch, and when;
• the documents the brand attached, such as lab reports, genotype reports and its FSSAI licence number;
• that the record has not been changed since it was confirmed.

It cannot show:

• that the facts in the record are true. IndiTrace records what the brand provides. It does not test ghee, genotype cattle, inspect dairies or check the documents;
• that the ghee meets the FSSAI standard. Only a lab test can show that;
• that the ghee is "A2" in any sense FSSAI recognises. FSSAI has not set a standard for that;
• any health benefit.

The food brands page covers how brands set up batch records and QR codes. For Badri Cow Ghee and other GI products, our GI tags index links to each official GI record.

Questions

Q: Is A2 ghee banned by FSSAI? No. FSSAI told sellers on 21 August 2024 to remove A1/A2 claims from milk and milk products, including ghee. It withdrew that advisory on 26 August 2024 "for further consultation and engagement with the stakeholders". When we checked FSSAI's published notices on 14 October 2026, we found no later notice. The general rules on truthful, substantiated claims still apply.

Q: Can a lab test tell whether ghee is A2? A2 is a difference in a milk protein, and ghee is at least 99.5% fat. FSSAI's 2024 advisory made the same point: the A1/A2 difference lies in the protein. So the usual evidence is genotyping the cows, not testing the ghee. Ask the brand for the herd's beta-casein genotype results.

Q: Are all desi cows A2? Not always. Indian zebu breeds carry the A2 form at high frequency, but a study published in 2023 found A1A2 animals in purebred Bargur and Umblachery cattle. Only genotyping shows which animals are A2A2.

Q: Is bilona ghee a certified category? No. FSSAI's ghee standard does not define bilona. The one exception is the GI specification for Uttarakhand Badri Cow Ghee, which describes a bilona method for that product only.

Q: Which tests show ghee is not adulterated? The FSSAI standard sets limits for moisture, milk fat, BR reading, Reichert Meissl and Polenske values, free fatty acids, iodine and saponification values and fatty acid composition. It also requires a negative Baudouin test and no β-sitosterol, which would indicate vegetable oil. Ask for a report that covers all of these and names the batch.

Sources

1. FSSAI, advisory to e-commerce FBOs on A1 & A2 claims, File No. RCD-02004/1/2023, 21 Aug 2024: https://www.fssai.gov.in/docs/whatsnew/advisories-orders/66c6d771eac97Advisory%20A1%20%20A2%20Milk%20%20Milk%20products.pdf
2. FSSAI, order withdrawing the 21 Aug 2024 advisory, 26 Aug 2024: https://www.fssai.gov.in/docs/whatsnew/advisories-orders/66cc48ad66e44New%20Doc%2008-26-2024.pdf
3. FSSAI, Food Products Standards and Food Additives Sixth Amendment Regulations, 2021 (ghee and milk fat products), notified 27 Dec 2021: https://www.fssai.gov.in/docs/whatsnew/gazette/61ce91bf0f10eGazettte_Notification_Ghee_Milk_31_12_2021.pdf
4. FSSAI, corrigenda to the 2021 ghee amendment, 19 Jan 2022: https://www.fssai.gov.in/docs/whatsnew/gazette/61ef798f6a025Corrigenda_Ghee_Milk_24_01_2022.pdf
5. FSSAI, compendium of the Food Products Standards and Food Additives Regulations, Version XVIII (10 Nov 2021), sub-regulation 2.1.8: https://fssai.gov.in/upload/uploadfiles/files/Compendium_Food_Additives_Regulations_12_11_2021.pdf
6. FSSAI, Advertising and Claims Regulations, 2018 (gazette, 19 Nov 2018): https://www.fssai.gov.in/docs/whatsnew/gazette/5bfd09e07399aGazette_Notification_Advertising_Claims_27_11_2018.pdf
7. FSSAI, "Misleading products in market in name of Ghee/Butter", 23 Jan 2023: https://www.fssai.gov.in/docs/whatsnew/advisories-orders/63cf4a03a7b7border.pdf
8. IP India GI Registry, application 1390, Uttarakhand Badri Cow Ghee (record, authorised users, GI Journal No. 203 copy): https://search.ipindia.gov.in/GIRPublicSearch/Application/Details/1390
9. IP India, Part A register of registered GIs (publish date 02/05/2026): https://ipindia.gov.in/storage/uploads/docs-operator/aa9ef4c8-ae0e-4717-9181-52b6a9479b82.pdf
10. EFSA, "Review of the potential health impact of β-casomorphins and related peptides", EFSA Journal 2009: https://www.efsa.europa.eu/en/efsajournal/pub/231r
11. Giribaldi et al., "A2 Milk and BCM-7 Peptide as Emerging Parameters of Milk Quality", Frontiers in Nutrition, 2022: https://www.frontiersin.org/journals/nutrition/articles/10.3389/fnut.2022.842375/full
12. Raja, Rajendran and Ganapathi, "Detection of A1 and A2 Alleles at Beta-casein Locus in Bargur and Umblachery Cattle Breeds by Allele-specific PCR", Indian Journal of Animal Research 57(1), 2023, doi:10.18805/IJAR.B-4273: https://arccjournals.com/journal/indian-journal-of-animal-research/B-4273
13. FSSAI FoSCoS licensing portal: https://foscos.fssai.gov.in/
14. TeamLease RegTech, summary of the Ghee Grading and Marking Rules, 2024 (secondary; gazette text not yet checked): https://teamleaseregtech.com/updates/article/33628/ghee-grading-and-marking-rules-2024